As part of national implementation of the CCD2 (Consumer Credit Directive 2) in Finland, the Financial Supervisory Authority (FIN-FSA) is extending its supervision to cover new consumer credit providers and consumer credit intermediaries. As part of this, new registration notifications for credit intermediaries are to be filed to the FIN-FSA from 20 March 2026. The legislative amendments enter into force 20 November 2026.
Broader application of consumer credit regulation
Essentially, due to the legislative amendments, consumer credits free of interest and charges will – except for specific exemptions – in the future also fall within the scope of Finnish consumer credit regulation. This means that current business models of several market participants will be subject to Finnish consumer credit regulation as of 20 November 2026. For such market participants, this means that the following key requirements, inter alia, must be complied with:
- Obligation to follow good lending practices (including rules on marketing practices).
- Obligation to provide consumers with information related to credit arrangements.
- Obligation to have written policies in place on minimum qualifications required for relevant functions and positions.
- Obligation to ensure that relevant employees have sufficient know-how (i.e. obligation to arrange trainings and monitoring actions).
- Obligation to retain records on credit arrangements.
- Obligation to have necessary registration or authorisation at the FIN-FSA in place.
New parties subject to obligation to register at the FIN-FSA
The following new domestic and foreign entities will be required to register with the FIN-FSA and will consequently fall under the FIN-FSA’s supervision:
- traders providing consumer credit as their main business, where the credit provided is interest-free and free of charges,
- traders providing consumer credit only as a side business to finance the purchase of the consumer goods they sell, excluding micro-enterprises and SMEs whose credit is interest-free and free of charges, and
- traders intermediating consumer credit, excluding credit institutions as well as micro-enterprises and SMEs that engage in credit intermediation as a side business only to finance the purchase of the consumer goods they sell.
Furthermore, the registration requirement is extended to apply to all FIN-FSA supervised entities that grant consumer credit, except for credit institutions and payment institutions where credit is granted related to payment services.
Impact on existing credit arrangements
The regulatory change will not have direct impact on current credit arrangements where agreements have been concluded before 20 November 2026. However, due consideration is required when renewing old credit arrangements or when continuing contractual relationships that have been concluded before 20 November 2026.
Essentially, at this stage market participants shall consider, inter alia, the following:
- Current business models and credit arrangements shall be duly assessed, so that it is clear whether a registration as credit provider or credit intermediary shall be applied for at the FIN-FSA.
- Depending on the nature of current operations, a registration application might need to be filed to the FIN-FSA at latest 20 May 2026 to ensure smooth business continuity.
- Terms and conditions applied on current credit arrangements shall be carefully evaluated, especially regarding renewal terms, so that any necessary adjustments are made to all legal documents before the legislative amendments enter into force 20 November 2026.
- Where necessary, new and/or additional terms and conditions shall be drafted to cover operations from 20 November 2026.
- In addition to preparation of registration applications, preparations for personnel trainings shall also be started. This is necessary so that know-how for relevant employees is ensured from 20 November 2026.
- Strategies for contractual management shall be prepared. This is important as consumer credit agreements currently in force (especially those valid on an ongoing basis) and still falling outside of the scope of consumer credit regulation might become subject to the said regulation from 20 November 2026. This might be caused either directly due to the legislative amendments, or, for example, if a credit agreement is amended or renewed from 20 November 2026 onwards so that a new agreement is deemed to be created.
What’s next?
Once the relevant government decrees have been published, the FIN-FSA’s website will be updated to provide more detailed information about the registration requirements and the procedure and registration.
Entities intending to provide credit or intermediate consumer credits from 20 November 2026 onwards shall start internal assessments to ensure that business operations are amended where necessary and any required registration is applied for.
The FIN-FSA will accept registration notifications from 20 March 2026 regarding credit intermediaries falling within the scope of the new Act on Certain Consumer Credit Intermediaries. Other parties may proceed with registration immediately. Registration applications filed no later than by 20 May 2026 will be processed by the time the legislative amendments enter into force.